Privacy Policy

Last updated: August 20, 2024
Please see our Privacy Snapshot for a high-level overview of our privacy practices.

1. Introduction

At Hilco IP Services, LLC d/b/a Hilco Streambank ("us", "we", "our" or the "Company") we value your privacy and the importance of safeguarding your data. This Privacy Policy (the "Policy") describes our privacy practices for the activities relating to our website https://ipv4.global ("Website"). As per your rights, we inform you how we collect and handle personal data relating to individuals. In this Policy, personal data ("Personal Data") refers to any information that on its own, or in combination with other available information, can identify or lead to identifying an individual. The office locations of where Hilco Streambank can be found https://hilcoglobal.com/contact/.

We are committed to protecting your privacy in accordance with the highest level of privacy regulation. It is important the personal data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

This Policy does not apply to third-party applications, websites, products, services or platforms that may be accessed through our Website. These sites are owned and operated independently from us, and they have their own separate privacy and data collection practices. Any Personal Data that you provide to these websites will be governed by the third-party's own privacy policy. We cannot accept liability for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.

2. Personal Data We Collect

What Personal Data We Collect
When you use our products and/or services on our Website, we collect the following types of Personal Data:

• Account Information such as your name, email address, and password
• Payment Information such as your billing address, phone number, credit card, debit card or other payment method. We rely on Stripe and Escrow.com, our third party payment providers, to process payment data and we do not have direct access to your financial data. You can find information about the payment services providers' privacy policies and practices at: https://stripe.com/gb/privacy and https://www.escrow.com/legal.
• Purchase Information specifically if personalized or unique
• Mobile device specific identifiers such as make and model, IMEI and phone number
• Physical business address
• Work related information such as your occupation, employment details
• IPv4 information for sales listings and requests

When you reach out to us using our "Contact Us" page, we will collect the following types of Personal Data:

• First name, last name
• Email address, phone number
• Company affiliation
• Interest area
• Details of enquiry

How We Collect Your Personal Data
We collect Personal Data from the following sources:

From You. You may give us your Account Information, Payment Information, Financial Information, Demographic Data, Purchase Information, Content, Feedback, Product Information, by filling in forms, using our products or services, entering information online or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide, for example, when you:

• Create an account or purchase products on our Website;
• Use our products or services;
• Create content through our products or services;
• Express interest in our products or services;
• Downloading software and/or our mobile application;
• Subscribe to our newsletter;
• Complete a voluntary market research survey;
• Contact us with an inquiry or to report a problem (by phone, email, social media, or messaging service);
• When you access our Website via social media;

Automated technologies or interactions: As you interact with our Website, we may automatically collect the following types of data (all as described above): Device Data about your equipment, and Usage Data about your browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie section (below) for further details. This information may include:

• Device IDs
• Login information
• IP Address
• Time stamps
• Authentication records
• General location information
• Individual Products you view
• Web terms or searches that led you to the site
• Time zone
• Other operational data.

We also use services provided by third-party providers that employ cookies, local storage and similar technologies to record and allow us to review replays of user sessions when you use our Website. The replays may include users' clicks, mouse movements, scrolls, text entered (including any contact data where tasks carried out via our Website remain uncompleted), and time spent on the webpage during those sessions and other data. These replays help us better understand the activity occurring on our Website, diagnose usability problems, optimize the user experience and provide us with information that we may use to improve our Website and/or to help us to develop new services.

Third parties: We may receive Personal Data about you from various third parties, including:

• Device and Usage Data from third parties, including analytics providers such as Google;
• Account Information from social media platforms when you access our Website using such social media platforms;
• Content from communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks;
• Account Information from third parties, including organizations (such as law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction.

If you provide us, or our service providers, with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Policy. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information set out in the "Contact us" section below.

Data we collect from third parties

We may receive your Personal Data from third parties such as companies subscribing to Hilco Streambank services, partners and other sources. This Personal Data is not collected by us but by a third party and is subject to the relevant third party's own separate privacy and data collection policies. We do not have any control or input on how your Personal Data is handled by third parties. As always, you have the right to review and rectify this information. If you have any questions you should first contact the relevant third party for further information about your Personal Data. Where that third party is unresponsive to your rights, you may contact the Data Protection Officer at Hilco Streambank (contact details below).

Our Website and services may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties' privacy statements, which you should review to better understand those third parties' privacy practices.

3. How We Use Your Personal Data

We use Personal Data for the following purposes:

• To provide our Website. We use Personal Data to operate, maintain, and provide you with our Website (including our products and services, to process your payments, to fulfil orders). In particular, we use Personal Data to enter into a contract with you or to perform our contractual obligations under our [Terms of Use].
• To communicate with you. We use your Personal Data to respond to your inquiries, comments, feedback, questions and setting up events. We do so to perform our contract with you or where it is in our legitimate business interests.
• To send administrative information to you For example, we may send you information regarding our services and changes to our terms, conditions, and policies for the performance of our obligations under our [Terms of Use].
• For analytics and product improvement. Where it is in our legitimate business interests, we use your Personal Data for other business purposes, such as data analysis, identifying usage trends, improving the content and functionality of our Website, developing new products and features and evaluating and improving our Website, our marketing and your experience.
• To protect our Website. It is in our legitimate business interests to prevent fraud, criminal activity that could be damaging for us and for you, or misuses of our Website, and to ensure the security of our IT systems, architecture, and networks.
• For compliance and legal reasons. We may use Personal Data to comply with legal obligations, and it is in our legitimate business interests to use your Personal Data to defend us against legal claims or disputes, including to:
  • protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • enforce the Terms of Use that govern the Website;
  • comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
• To send you communications about our products and services. We may use Personal Data to send you newsletters and other marketing communications such as via email, phone, SMS. You can opt out of our marketing-related emails by following the opt-out or unsubscribe instructions in the emails you receive from us. You may opt out of receiving text messages from us by replying "STOP" to the text message you receive from us. You may also opt out of receiving marketing communications from us by contacting us as provided in the "Contact Us" section below. You may continue to receive service-related and other non-marketing communications.. Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.
• For interest-based advertising. We engage advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically-collected data described above) about your interactions over time across our Website, our communications, and other online services, and use that information to serve online ads that they think will interest you. Except where we rely on your consent, it is in our legitimate interests to use your Personal Data for the purposes described above.

4. Disclosure of your Personal Data

In certain circumstances we may disclose your Personal Data to third parties as set forth below:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may disclose Personal Data to vendors and service providers, including e-commerce providers, providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, and payment processors (such as Stripe, as detailed above), customer relationship management, customer support services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us.
• Buyers and sellers of IP addresses: If you are buying or selling IP addresses, we may share your Personal Data at your direction with the buyer or seller to complete the transaction.
• Professional advisors: We may share your Personal Data with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Advertising partners. Third party advertising companies, including for the interest-based advertising purposes described above.
• Public and government authorities: We may share your Personal Data with public and government authorities, courts and regulators in order to respond to a legal request or comply with a legal obligation.
• Mergers or acquisitions: If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

5. International Data Transfer and Storage

Where possible, we store and process data on servers within the general geographical region where you reside (note: this may not be within the country in which you reside). Your Personal Data may also be transferred to, and maintained on, servers residing outside of your state, province, country or other governmental jurisdiction where the data laws may differ from those in your jurisdiction. When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for Personal Data and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision/regulation for transfers outside of the European Economic Area and United Kingdom, or on contractual protections for the transfer of Personal Data. For more information about how we transfer Personal Data internationally, please contact us as set out in the "Contact Us" section below.

6. Cookies

What are Cookies?
Cookies are small text files placed onto your device (computer, mobile phone, etc.) by certain websites that you visit and generally collect standard internet log information and visitor behaviour information. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.

Cookies can be 'first-party' or 'third-party' depending on the domain that sets them. First-party cookies are set by us and information collected from these cookies is used by us in accordance with our Privacy Policy. Third-party cookies are set by third parties and information is collected and used in accordance with those parties' privacy policies. Our Website uses both persistent and session cookies:

• Session Cookies. These cookies are temporary cookies that remain on your computer or device until you leave our Website. They allow our Website to link your actions during a browser session. We may use these for a variety of purposes such as remembering what you clicked on, on the previous page visited. A session starts when a user opens a browser window and ends when the browser window is closed, following which all session cookies expire and are deleted;
• Persistent Cookies. These cookies remain on your device for much longer or until you manually delete them (how long the cookie remains on your device will depend on the duration or "lifetime" of the specific cookie, as well as your browser settings). Persistent cookies may be used for a variety of purposes including remembering users' preferences and choices when using a site or to target advertising.

How we use cookies
To give you the best experience possible, we use the following types of cookies:

• Strictly Necessary. These cookies are necessary for our Website to function correctly. They enable you to move around our Website and use our Website features. Without these cookies, you would not be able to navigate between pages or use certain core features of our Website. As these cookies are necessary for the provision of our Website to you, we do not require your consent for their use.
• Analytics. These cookies help us understand how you interact with our Website by providing information such as the pages visited, the time spent on the Website, and any issues encountered, such as error messages. The information these cookies collect are for the purposes of generating aggregated statistics and they help us improve the way our Website works. Where required by law, we will obtain your consent before placing Analytics Cookies on your device.
• Functionality Cookies. These cookies allow our Website to remember if you have previously visited our Website or the choices you make on our Website to provide a more personalized online experience. Where required by law, we will obtain your consent before placing Functionality Cookies on your device.
• Marketing. These cookies are used to deliver content that is more relevant to you and your interests. They may be used to deliver targeted advertising or to limit the number of times you see an advertisement. They help us measure the effectiveness of advertising campaigns on our Website and may also result in your seeing advertisements for some of our products you may be interested in when visiting other Website. We may share this information with third parties, including advertisers. Where required by law, we will obtain your consent before placing Marketing Cookies on your device.

Depending on your location, the maximum expiration period for the cookies above is two years.

How to control cookies

Depending on where you access the Services from, you may be presented with a cookie banner or other tool to provide permissions prior to cookies other than Strictly Necessary Cookies being set. In this case, we will only set these cookies with your consent.

To alter the way in which we collect information from you, you can also visit our Cookie Manager.

You can also limit tracking by:

• Blocking cookies on your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. If you disable or delete cookies, however, you may have to manually adjust some preferences every time you visit the Website and some functionalities may not work. Please see the following links for instructions on how to turn off or delete cookies on popular browsers: Chrome, Firefox, Microsoft Edge, Safari (Mac), Safari (Mobile/IOS).
  For more information on cookies and how they can be managed and deleted please visit www.allaboutcookies.orgor www.networkadvertising.org/choices.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Google Analytics.We use Google Analytics to help us better understand how people engage with our Services by collecting information and creating reports about how users use our Services. For more information on Google Analytics, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Using privacy plug-ins or browsers. You can block our services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo,Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
• Platform opt outs. The following platforms offer opt out features that let you opt out of use of your information for interest-based advertising:
  • Google, LinkedIn
• Advertising industry opt out tools.You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance for Websites
  • Digital Advertising Alliance for Mobile Apps
  • Network Advertising Initiative

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

7. How We Keep Your Data Safe

We have appropriate organizational safeguards and security measures in place to protect your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

The communication between your browser and our Website uses a secure encrypted connection wherever your Personal Data is involved.

We require any third party who is contracted to process your Personal Data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law.

In the unfortunate event of a Personal Data breach, we will notify you and any applicable regulator when we are legally required to do so.

8. Children's Privacy

We do not knowingly collect Personal Data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Data to us, please contact us and we will endeavor to delete that Personal Data from our databases.

9. Retention

We retain Personal Data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Personal Data, the purposes for which we use Personal Data and whether we can achieve those purposes through other means, any permissions you give us with regards to your Personal Data, and the applicable legal and regulatory requirements.

10. Your Rights for Your Personal Data

Depending on your geographical location, your rights are subject to local data privacy regulations. These rights may include:

• Right to Access
  You may have the right to learn whether we are processing your Personal Data and to request a copy of the Personal Data we are processing about you.
• Right to Rectification
  You may have the right to have incomplete or inaccurate Personal Data that we process about you rectified.
• Right to Erasure
  You may have the right to request that we delete Personal Data that we process about you.
• Right to Restriction of Processing
  You may have the right to restrict our processing of your Personal Data under certain circumstances.
• Right to Portability
  You may have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to transmit such Personal Data to another controller under certain circumstances.
• Right to Opt Out of Selling and Sharing for Targeted Advertising
  You may have the right to opt out of (1) the sale of Personal Data; or (2) the processing of your Personal Data for purposes of targeted advertising. We share information with third-party advertising partners and allow them to collect information about your use of the Website to show you ads as described in the "How we use your personal data" and "Disclosure of your Personal Data" sections above. Our disclosure of information to these partners may be considered a "sale" or "sharing" of Personal Data or "targeted advertising" under applicable laws. You can opt out of these disclosures and limit our use of tracking technologies as described in this Privacy Policy or by clicking the "Your Privacy Choices" link in the footer of our Website. You may also have the ability to reject or toggle off optional cookies by enabling the Global Privacy Control setting within the browser that you use to access our Website. Learn more at the Global Privacy Control website. Please note that your opt out will be specific to the device and browser you use when you opt out. We do not knowingly "sell" or "share" the Personal Data of consumers under 16 years of age.
• Right to Opt Out of Profiling
  You may have the right to opt out of the processing of your Personal Data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. We do not engage in profiling in connection with decisions that produce legal or similarly significant effects.
• Right to Objection
  Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation.

Nondiscrimination and nonretaliation

Depending on your location, you may have the right not to be denied service or have an altered experience for exercising your rights.

File an Appeal

Depending on your location, you may have the right to file an appeal with us based on our response to you exercising any of these rights.

File a Complaint

If you are unhappy with how we are processing your Personal Data or in the event you disagree with how we resolved your appeal, you may have the right to bring a complaint to your local data protection authority or competent regulator.

Withdrawing Consent

If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, for example where you wish to opt out from marketing messages that you receive from us. If you wish to withdraw your consent, please contact us using the information found at the bottom of this page.

How to Exercise Your Rights

You can make a request to exercise any of these rights in relation to your Personal Data by using the details in the "Contact Us" section below.

For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information.

Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws.

11. Changes

We may modify this Policy at any time. If we make changes to this Policy then we will post an updated version of this Policy at this Website. When using our services, you will be asked to review and accept our Privacy Policy. In this manner, we may record your acceptance and notify you of any future changes to this Policy.

12. Contact Us

To exercise your rights or ask a question about your Personal Data, we've made the process simple: To contact us, please email info@ipv4.global

Hilco Streambank is the controller of (or the business for) your personal data.
Data Privacy Officer of IPv4.GLOBAL
1500 Broadway, 26th Floor, New York , New York , 10036

Privacy Snapshot

Below is a high-level snapshot of how we collect, use, and disclose your Personal Data, but you need to read the entire Privacy Policy for complete information.

*As described further in our Privacy Policy, we may disclose all categories of Personal Data to our service providers, affiliates, and professional advisors for the purposes described in the Privacy Policy. Also, we may disclose Personal Data to authorities and others for legal and compliance purposes, and with business transferees in the context of an acquisition or the sale of our business or another corporate transaction.